Rolfs v. Commissioner
United States Tax Court
On Apr. 30, 1964, Rolfs and Arnold exercised statutory restricted stock options by giving their interest-bearing promissory notes for the purchase of a specified number of shares of stock of their employer, GB&B, pursuant to the latter's 1963 Employees' Stock Purchase Plan. Under the plan, cash payment had to be completed or a promissory note taken up no later than June 30, 1965, as a condition of the issuance of shares.
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On Apr. 30, 1964, Rolfs and Arnold exercised statutory restricted stock options by giving their interest-bearing promissory notes for the purchase of a specified number of shares of stock of their employer, GB&B, pursuant to the latter's 1963 Employees' Stock Purchase Plan. Under the plan, cash payment had to be completed or a promissory note taken up no later than June 30, 1965, as a condition of the issuance of shares. Rolfs and Arnold took up their notes respectively on May 1 and June 30 of 1965. On Oct. 14, 1965, they sold all their GB&B stock. Held, each sale was a disqualifying…
1Opinion of the Court
OPINION
Tietjens, J.udge:
In these consolidated cases the Commissioner determined deficiencies in the income tax of petitioners herein as follows:
Petitioner ' Docket No. 1 Year Deficiency'
John H. Rolfs-i_______ 5618-70 1965 $2,375. 00
Maxwell A. Arnold, Jr., and Patricia Arnold-_ 5708-70 1965 4,452.13
John H. .Rolfs filed an individual Federal income tax return for-1965 with the.district director of internal revenue in San Francisco,.Calif. He resided in Sausalito, Calif., at the time.of filing the petition herein. Maxwell A. Arnold, Jr., and Patricia Arnold have, at all pertinent times been…
2Cases cited9 opinions
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Merrill v. CommissionerUnited States Tax Court · 1963
- Pike v. CommissionerUnited States Tax Court · 1965
- Weir v. CommissionerUnited States Tax Court · 1948
- George W. S. Swenson and Ruth E. Swenson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
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3Cited by2 opinions
- John H. Rolfs, and v. Commissioner of Internal Revenue, AndCourt of Appeals for the Ninth Circuit · 1973
- Rolfs v. CommissionerUnited States Tax Court · 1972